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On February 16, 2016, TEI submitted comments to the Internal Revenue Service offering a definition of "minor assembly" for purposes of the domestic production activities deduction ("DPAD") of 26 U.S.C. § 199. We submitted these comments pursuant to the REG-136459-09 notice of proposed rulemaking, which proposed various changes in the regulations surrounding the DPAD. These comments also offered an alternative new Example 9 from what was suggested in REG-136459-09, an example generally regarding as attempting to overturn by regulation the holding in United States v. Dean, 945 F. Supp. 2d 1110 (C.D. Cal. 2013).